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Johnson & Johnson, DePuy Pay $76.9M To Settle Foreign Bribery Claims

(Mealey's) - Johnson & Johnson (J&J) and subsidiary DePuy International Ltd. will pay $76.9 million to resolve criminal and civil allegations in the United States and in the United Kingdom that they paid kickbacks to doctors in Greece, Poland, Romania and Iraq to use the companies'...

Johnson & Johnson Deferred Prosecution Agreement-Part II: Compliance Program Best Practices

Yesterday we reviewed the background facts of the Johnson & Johnson (J&J) Deferred Prosecution Agreement (DPA) and the issue of self-reporting. In this posting we will review some of specific compliance program best practices which Johnson & Johnson agreed to implement. I. Attachment...

Johnson & Johnson Becomes the Newest Member of the FCPA Top 10 Settlements List

Current trends in FCPA enforcement are evident in the latest settlement with Johnson & Johnson. U.S. v. Depuy, Inc. , (D.D.C. Filed April 8, 2011); SEC v. Johnson & Johnson , Civil Action No. 1:11-cv-00686 (D.D.C. Filed April 8, 2011). To resolve the case with DOJ and the SEC the company...

A Focus On World-Wide Coin

This article was reprinted with permission from FCPA Professor The SEC's administrative order ( here ) in the December 2012 Allianz enforcement action cited SEC v. World-Wide Coin Investments , 567 F.Supp. 724 (N.D. Ga. 1983) [ an enhanced version of this opinion is available to lexis.com subscribers...

Las Vegas Sands Reporting – Not The Media’s Finest FCPA Moment

This article was reprinted with permission from FCPA Professor Las Vegas Sands has been the subject of much FCPA scrutiny since October 2010 when Steven Jacobs (the former President of the company's Macau operations) filed a civil cause against the company in Nevada State court alleging various...

The SEC Frequently Alleges or Finds Only Books and Records and Internal Controls Violations in FCPA Enforcement Actions

This article was reprinted with permission from FCPA Professor This recent post highlighted critical commentary regarding the recent BHP Billiton enforcement action. One theme from much of the commentary was that the BHP action was somehow unique in charging (or finding as the case may be since...

Next Up – Bristol-Myers

This article was reprinted with permission from FCPA Professor First it was Johnson & Johnson (see here – $70 million enforcement action in April 2011). Then it was Smith & Nephew (see here - $22 million enforcement action in February 2012). Then it was Biomet (see here –...